Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT allowed the assessee's appeal, setting aside the disallowance of interest on loans under the head "income from other sources" made by the AO and sustained by NFAC. It held that, where no fresh loans were borrowed or advanced during the relevant year and only opening balances existed, the assessee was not required to re-establish a one-to-one nexus between interest paid and interest received under s.57(iii). As the nexus had already been accepted in earlier and subsequent years and full details of loans and interest were furnished, ITAT directed the AO to grant the claimed interest deduction.
ITAT allowed the assessee's appeal, setting aside the disallowance of interest on loans under the head "income from other sources" made by the AO and sustained by NFAC. It held that, where no fresh loans were borrowed or advanced during the relevant year and only opening balances existed, the assessee was not required to re-establish a one-to-one nexus between interest paid and interest received under s.57(iii). As the nexus had already been accepted in earlier and subsequent years and full details of loans and interest were furnished, ITAT directed the AO to grant the claimed interest deduction.
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